Development of price setting methodology in controlled transactions between related parties within a group of companies.
An integrated approach to structuring and pricing of the intra-group agreements, optimization of value-added chain (taking into account OECD recommendations as part of the control measures on base erosion and profit shifting - BEPS).
Review of taxpayer’s operations aiming to establish, evaluate and develop measures to mitigate risks associated with the tax control of prices.
Preparation of transfer pricing documentation, including three-tiered documentation (country-by-country reporting, Master File, Local File) and notification of the participation in the MNE Group, as stipulated by the Kazakhstan legislation.
Preparation for tax inspections, assistance with appealing of the tax inspection results, support with dispute resolution related to the tax control of prices in the transactions between the related parties.
Evaluation of appropriateness, preparation of required documentation and information, support of the taxpayer with submission of application for conclusion of the advanced pricing agreements (including the agreement with the competent authorities of foreign states).
Transfer pricing ("TP") rules have existed in Kazakhstan for more than 20 years. During this period, Kazakhstan’s tax authorities have performed numerous TP audits many of which resulted in disputes ultimately resolved in court.
Recently, attention to TP has grown worldwide, both from authorities and businesses, including the framework for implementation of the initiatives developed by OECD for fighting base erosion and profit shifting (BEPS). Kazakhstan is no exception and implemented new types of TP reports. Nevertheless, revision of the Kazakhstan TP rules to bringing them in line with the best international practice is under consideration.
Along with the historic focus in Kazakhstan on export of resource commodities, increasing attention is paid to TP issues concerning financial transactions, purchase of services, import of consumer and industrial goods and licensing of intangibles.
We have assembled an extremely strong TP team consisting of local and international experts covering Kazakhstan and Eurasian Region. We work with different clients across various industries, typically addressing questions such as:
Contact us and we will provide you with comprehensive TP support. More information about the TP rules in Kazakhstan and assistance we offer is presented in our brochure.
Partner, Tax & Legal Services, PwC Kazakhstan
Тел: +7 727 330 3200
Partner, Leader Tax & Legal Services, PwC Kazakhstan
Тел: +7 717 255 0707
Senior Manager, Transfer Pricing, PwC Kazakhstan
Тел: +7 717 255 0707